Motor vehicle accidents that result in bodily injury are a very common occurrence in today's society. Before the advent and increase of automobile insurance laws, which often contain a provision that makes anyone operating a motor vehicle with the owner's permission an additional insured, special tort laws were developed to deal with liability for automobile accidents. For the most part, these laws are rarely used in present disputes or litigation due to the pervasive nature of modern automobile liability insurance. However, the special laws do still arise on occasion in motor vehicle accident cases.